MedicaidCoverageHigh impact
Public Health Emergency Unwinding
Maryland Medicaid·MD·Provider Transmittal
Effective date
May 11, 2023
We identified it
Jun 20, 2026
Summary
Maryland Medicaid ends the Public Health Emergency and transitions remaining flexibilities. Key changes: COVID-19 vaccines, tests, and treatments remain covered without cost-sharing through at least September 30, 2024 (with copay guidance expected for October 1, 2024); telehealth coverage (including audio-only) continues through June 30, 2025; School-Based Health Centers must now comply with federal clinic regulations (42 CFR § 440.90) requiring either practitioner or patient physically located at clinic; and balance billing for PPE remains prohibited with provider sanctions enforced.
Action Required
REQUIREMENTS:
1. By August 9, 2023 (HIPAA compliance deadline): Billing team and IT staff must ensure all telehealth platforms are HIPAA-compliant. Replace any non-HIPAA compliant technology (authorized during PHE through OCR discretion). Non-compliant platforms cannot be used after August 9, 2023.
2. Immediately (effective May 11, 2023): Billing team must update billing system to continue allowing claims for COVID-19 vaccines (CPT codes for vaccine administration), COVID-19 tests (OTC and laboratory), and COVID-19 treatments without cost-sharing through September 30, 2024. Do not apply copays during this period. Prepare for potential copay implementation October 1, 2024 pending MDH guidance.
3. Immediately: Billing team must ensure telehealth claims are billed with appropriate modifiers: use "-GT" modifier for two-way audio-visual telehealth and "-UB" modifier for audio-only telephonic services. Update billing software rules accordingly.
4. Immediately: For teledentistry claims, billing team must bill procedure code D0140 (Limited oral evaluation - problem focused) using Place of Service "02" to indicate telecommunication technology. Audio-only or telephonic teledentistry services are not reimbursable.
5. Immediately: School-Based Health Center (SBHC) billing teams must discontinue billing for telehealth services where neither practitioner nor patient is physically located at the clinic. Compliance required with 42 CFR § 440.90. For SBHC telehealth visits, bill using: POS code 03 (School) for students/associated families; appropriate modifier (-GT for audio-video, -UB for audio-only). Failure to comply will result in claim denials and potential sanctions.
6. By January 1, 2024: Verify that premium payment suspensions for EID Program enrollees remain in effect until this date. No disenrollments for non-payment until January 1, 2024.
7. By May 1, 2024: Verify that premium payment suspensions for MCHP Premium enrollees remain in effect until this date. No disenrollments for non-payment until May 1, 2024.
8. Ongoing: Front desk staff, billing team, and providers must ensure no balance billing occurs for covered services, including PPE. Educate all staff on balance billing prohibition. Document staff training. Violations result in program sanctions, suspension, or termination.
9. By September 30, 2024: Monitor for MDH guidance on whether copays will be required for COVID-19 vaccines, tests, and treatments beginning October 1, 2024. Be prepared to implement copay rules upon notification.